WHO IS DATA CONTROLLER OF YOUR PERSONAL INFORMATION?
HOW AND WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
The categories of information we collect can include:
Information you provide to us directly. We may collect personal information, such as your name, phone number, address, and email address when you sign up for our mailing list, respond to a survey, fill out a form, apply for a job with us, or otherwise communicate with us. We may also collect any communications between you and Local Alternative and any other information you provide to Local Alternative.
We use this information to operate, maintain, improve, personalize, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages. We may also send you Service-related emails or messages (e.g., account verification, updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Control Over Your Information” below.
WHY AND ON WHICH LEGAL GROUNDS DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
Please note that this notice on the legal grounds refers to the legal justifications under GDPR only. The reasons for using your personal information may differ depending on the purpose of the collection. Regularly we use your information on the following legal grounds:
We use your information in order to perform our contractual services or prior to entering into an agreement with you. If you use our Service or if you contact us to request our Service, we use your information to provide to you the features and functionality of the Service. Information we use includes: information we need to contact you or otherwise communicate with you; information to manage your customer account; information to enable the usage of Service; information necessary for customer support.
We use information if justified by our legitimate interests, except that these are overridden by your interests and fundamental rights and freedoms. The usage of your information may also be necessary for our own business interests, e.g., we may use some of your information to contact you and respond to your requests and enquiries, to administer our business including statistical analysis, to provide advertising or to identify potential cyber security threats. Where necessary, we may also use your information to pursue or defend ourselves against legal claims. If you are already a customer, we may use your email address and names for our email marketing campaigns. You can object to direct marketing use at any time and for no reason by following the link to unsubscribe at the bottom of our marketing emails.
We use information to comply with legal obligations. In order to comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., retain certain information according to tax or commercial laws).
We do not use your personal information for automated individual decision-making.
We, and our third-party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp (a unique ID that allows us to uniquely identify your browser, mobile device, or your account), and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
SHARING OF YOUR INFORMATION
We may share your personal information in the instances described below. The legal bases for such transfers of personal information according to the GDPR are set out in parenthesis. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
We may share your personal information with:
Third parties at your request. For example, you may have the option to share your activities on the Service with your friends through email or on various social media sites (legitimate interest/ consent);
Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, web hosting, or providing analytics services. These third parties include: Facebook, Inc., Google, Inc., Twitter Inc. and Microsoft Corporation. Any such service providers and advisors will be given limited access to personal information as is reasonably necessary for delivering their service and will, by appropriate data processing agreements, be bound to only process personal information on Local Alternative’s behalf and under its instructions (legitimate interest/ commissioned data processing);
Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings (legitimate interest); and
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
CONTROL OVER YOUR INFORMATION
How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Sites over time so that they may play or display ads on our Sites, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again. You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
HOW WE STORE AND PROTECT YOUR INFORMATION
Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
For data subjects who are in the EU, we will store personal information for as long as necessary to fulfil the purposes for which we collect the personal information, and in accordance with our legal obligations and legitimate business interests, except if required otherwise by law.
Local Alternative does not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
From children under the age of 16 who are in the EU, we will not process any personal information on the ground of a consent.
LINKS TO OTHER WEB SITES AND SERVICES
The Service may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.
RIGHTS FOR DATA SUBJECTS WHO ARE IN THE EUROPEAN UNION
If you are in the EU, you have the following rights in respect of your personal information that we hold:
a. Right of access. The right to obtain access to your personal information.
b. Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal data is inaccurate or incomplete.
c. Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
d. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
e. Right to portability. The right to portability allows you to move, copy or transfer personal information easily from one organization to another.
f. RIGHT TO OBJECT: YOU HAVE THE RIGHT TO OBJECT, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, AT ANY TIME, TO THE PROCESSING OF PERSONAL INFORMATION CONCERNING YOU WHICH IS BASED ON OUR LEGITIMATE INTERESTS INCLUDING PROFILING (E.G., CREDIT RATINGS). WE SHALL NO LONGER PROCESS THE PERSONAL INFORMATION UNLESS WE DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE THE INTERESTS, RIGHTS AND FREEDOMS OF YOU, OR FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS.
YOU HAVE THE RIGHT TO OBJECT TO AT ANY TIME TO PROCESSING OF PERSONAL INFORMATION CONCERNING YOU FOR PURPOSES OF DIRECT MARKETING, WHICH INCLUDES PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT TO THE PROCESSING FOR DIRECT MARKETING PURPOSES, YOUR PERSONAL INFORMATION WILL NO LONGER BE PROCESSED FOR SUCH PURPOSES.
g. Right to refuse or withdraw consent: Where the processing is based on consent, you have the right to either refuse the grant of consent or withdraw your consent at any time, without effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
HOW TO CONTACT US